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Western National Insurance Group v. Hanlon

United States District Court, D. Nevada

July 30, 2018

WESTERN NATIONAL INSURANCE GROUP, Plaintiff,
v.
CARRIE M. HANLON, ESQ., and MORRIS, SULLIVAN, LEMKUL & PITEGOFF, and DOES 1 through 10 and ROE CORPORATIONS I-X, Defendants.

          McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP, Dylan P. Todd, Attorneys for Carrie M. Hanlon, Esq. and Morris, Sullivan, Lemkul & Pitegoff

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI, Peter M. Angulo, Esq., Attorneys for Western National Insurance Group

          STIPULATION AND ORDER TO EXTEND ALL DISCOVERY DEADLINES (FOURTH REQUEST)

         Defendants CARRIE M. HANLON, ESQ. and MORRIS, SULLIVAN, LEMKUL & PITEGOFF, by and through their attorneys of record of the law firm McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP, and Plaintiff WESTERN NATIONAL INSURANCE GROUP, by and through attorneys of record of the law firm OLSON, CANNON, GORMLEY, ANGULO, & STOBERSKI, hereby file this Stipulation and Order to Extend All Discovery Deadlines (Fourth Request) for 60 days.

         I. DISCOVERY COMPLETED BY THE PARTIES

         The parties served their FRCP 26(A) Initial Disclosures. The initial disclosures contained numerous documents with voluminous page counts. Due to the amount of relevant documents generated by the underlying case, Plaintiff's initial production alone totaled approximately 2, 967 pages. Since that time, significant additional documentation has been provided by Plaintiffs, as well as Defendants.

         Plaintiff has propounded Interrogatories, Requests for Production of Documents, and Requests for Admissions on all Defendants. Responses were originally due on September 8, 2017. Due to the volume of the requests (there were nearly 75 Requests for Admission propounded on each Defendant) and an ongoing issue as to the amount of privileged material, more time was needed to adequately respond. Responses to this discovery were provided on October 10, 2017.

         Defendants propounded written discovery in the form of Interrogatories, Requests for Production and Requests for Admission to Plaintiffs on October 11, 2017. This written discovery was propounded following receipt and review of the extensive initial document disclosures by Plaintiff. Plaintiff's counsel's previously-discussed medical procedures and family commitments required him to be unavailable and out of the office for all of November, 2017. Defendants granted additional time to respond to the written discovery, and received the written responses on December 8, 2017. Plaintiff also served its First Supplemental FRCP 26 Disclosure on December 5, 2017.

         Defendants served subpoenas and custodian of records deposition notices for the law firms of Phillips, Spallas & Angstadt (PSA) and the Law Offices of Cory Hilton. PSA law firm did not respond to the subpoena, and a notice of non-appearance of the custodian of records was taken on September 13, 2017. Defendants did receive documents per the subpoena later that day. There are still some lingering issues regarding certain objections to the subpoena. It is possible that this matter may need to come before the Court in a motion to compel, however in the interest of economy, Defendants have agreed to hold off on this particular matter until documents from Cory Hilton have been produced.

         Defendants have granted Cory Hilton several extensions to provide his firm's correspondence file relating to the Herbster v. Classic Landscapes litigation in the Eighth Judicial District Court. In our previous stipulation (Dkt. # 34), we explained the issues and difficulties surrounding the production of these documents. After significant deliberation and meet and confer efforts, Morris Sullivan was able to finally obtain the requested documentation. The production included a total of 23, 320 pages of documents that were produced in Defendants Second Supplemental Rule 26 Production on March 27, 2018. There are no further issues regarding Mr. Hilton's file.

         The depositions of Plaintiff's witnesses Lorraine Walsh and Maggie Kirschner took place on March 15th and 16th, respectively. The deposition of Plaintiff's witness/representative John Buckley was also scheduled to take place on March 16th, however due to the duration of Ms. Kirschner's deposition, Mr. Buckley was unable to proceed on the date scheduled. The parties agreed to move the deposition to a time more agreeable to everyone's schedule.

         II. DISCOVERY WHICH REMAINS TO BE COMPLETED

         The following depositions of the parties remain:

1) Plaintiff- John Buckley
2) Defendants- Carrie ...

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